2. What data do we handle about you?

‍Summary: We have information about who you are and how you use the services of Wayra.

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Detail:The information we have about you includes information about who you are and how you use the services of Wayra.

Who you are: Your name and surnames, user ID and email.

‍How do you use the services of Wayra: Calls to which you have applied and startup profiles that you have created in Wayra.

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3. How do we obtain and where does the data come from?

‍Summary: It is mainly you who directly provides us with your data.

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Detail:

‍Mainly we obtain your data directly from you:

You provide them to us directly through the registrationform, the configuration options of your profile once logged in https://de.wayra.co/, or when you contact us so that we can give you support and contribute additional data. Remember that the personal information provideddirectly must always be real, accurate and up-to-date. We will put at your disposal the necessarytools so you can update or rectify this information.

We observe them when you use or we obtain them from your device (eg the operating system ofyour device or the network from which you connect). Remember that you can review and managethe permissions you grant to Wayra to obtain data from your device through the options availableon your terminal (Android, iOS or web).

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4. For what and why do we use your data?

‍Summary: We use your data to provide you with the service of Wayra. We also use them for other legitimatepurposes with the goal of communicating with you, knowing the use you give to Wayra or even complyingwith some legal obligations that are applicable to us.

Detalle:

We manage your data to:

That you can enjoy Wayra and all its functionalities (rendering the service).

Communicate and be in contact with you with the goal of informing you about the products andservices that are relevant to you through various channels such as, for example, the email, fromWayra. To be honest with you, our goal is that you download and register in Wayra (if you havenot already done so), as well as that you are happy with the services Wayra, know them and usethem actively.

Know how you use the products and services Wayra to:

○ Detect trends and correlations in order to understand and predict in an aggregate waythe use of these services and the needs you may have as a user.

○ Make better business decisions, such as how to improve the products and servicesWayra, as well as your experience, or how to make the communication actions that weindicated in the previous point more effective.

○ Prepare reports with added data on the evolution in the number of active users or howcertain functionalities are used.

○ Check if you have performed a specific action through Wayra.○ Monitor compliance with quality of service levels (eg to debug and detect errors).

○ Prevent and detect fraudulent, malicious or illegal activities (especially when this mayaffect other users).

Conduct surveys in order to ask you and know your opinion about the Wayra or its services andfunctionalities.

Collaborate and respond to orders or requirements of the authorities.

Report or make known to the authorities fraudulent, malicious or presumably illegal actions.

Defend against lawsuits, complaints and / or claims of any kind.

Guarantee the physical security of the networks and the information technologies that we use toprovide you with our services and products.

Lastly, it is possible that in the future we need to manage your data for additional purposes with the aim ofcontinuing to innovate and offer you added value services.

Do not worry, in that case we will always analyze if these purposes are compatible with your expectationsand with the principles that govern our privacy policy and cookies.

In any case, we will previously take all necessary actions to ensure compatibility such as, for example,additional transparency, control or security measures.

We use your data for the above purposes because:

We need them so that you can enjoy [name P & S] and its functionalities in accordance with itsconditions of use.

We need them to comply with certain legal and regulatory obligations (eg, obligation tocollaborate and respond to the requirements of the authorities).

Some of the purposes are necessary for the legitimate business interests of Telefónica S.A. ,although you can always oppose them (eg, communicate and be in contact with you to inform youabout products and services Wayra).

Because you have given us your permission for us to process your data for certain purposes (eg,those permissions you grant us during registration so that we can access information about yourdevice).

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5. How long do we keep your data?

‍Resumen: There are certain reasons that legitimize us to conserve your data, although we will only conserve andmanage them as long as they are necessary for the purposes indicated in point 4 of this policy. Thespecific conservation period will depend on the type of data and for what and why they are used.

Detalle: In general, we will no longer keep your data at the time it is not necessary to continue providing you withthe service of Wayra. However, there are some exceptions to this general rule that we explain below.

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In this matter, there are some purposes that persist and continue even after the removal of Wayra account.Specifically, we must continue to keep some information about you and how you used Wayra to:

Collaborate with the authorities and respond to their information requirements.

Defend against lawsuits, complaints and / or claims.

Prevent fraud, abuse or illicit actions.

Test and verify that you had a user account in Wayra.

However, during this additional period we will apply a series of additional measures and actions to ensurethe protection of your information and your privacy. This type of measures may include, for example, thefunctional separation, pseudonymization, and / or encryption of your data and information.

Also, we will take all reasonable measures to ensure that your data is rectified or deleted when inaccurate.

6. Who has access to your data (besides Telefónica S.A.)?

‍Summary: Besides Telefónica S.A., others who have access to your personal data are: our suppliers andcollaborators, other companies of the Telefónica Group, as well as the authorities with whom wecollaborate and interact. The access to your data that we provide to these third parties is always for lawfulpurposes and only during the period of time strictly necessary for it.

Detail: We need to share your data with certain third parties that we indicate below, always in relation to thespecific purposes for which we treat your data, described in point 4, and for a period strictly necessary forit.

Specifically, this involves giving access to your data to:

Our suppliers and collaborators, as well as the companies that they subcontract, which help us toprovide the services of Wayra, to communicate and be in contact with you, as well as to conductsurveys and to know how you use Wayra. Some of these suppliers and collaborators (eg,Amazon, Google or Telefonica USA) are located in the United States and their services,infrastructure, systems or contracted tools are always contracted by Telefónica S.A. under theEU-US agreement PrivacyShield, which gives maximum guarantees for the transfer of your datathat is made to that country

Other Telefónica Group companies whose identity can be consulted in the following link, with aninternal administrative and commercial management purpose, so that companies cancommunicate and contact you with information about products, promotions, offers and / orservices.

Authorities (eg, security forces and state security forces or judicial bodies), national and / orinternational, that require legal access to your information, as well as, those other Authorities withwhom we need to share your information to defend ourselves against possible lawsuits,complaints and / or claims of any kind, as well as to bring to your knowledge fraudulent, maliciousor allegedly illegal actions.

In any case, Telefónica S.A. always guarantees the highest level of protection during the access that thesethird parties have to your data and information, for example, reaching data management agreements withthem or through the establishment of measures of appropriate protection to ensure confidentiality andsecure treatment of your data.

7. What are your rights and how can you control your data?

‍Summary: The regulations give you a series of rights regarding the data and information that we manage about you.Specifically, the rights of access, rectification, deletion, limitation, opposition, portability, as well as notbeing subject to automated decisions and to remove your consent at any time. Some of these rights canbe made directly through the Wayra app and for others you will have to write to the address privacidad@wayra.co to execute them.

Detail:

You can perform the following data protection rights against Telefónica S.A.:

Access right: right to request the details of the data we have about you and how we treat them,as well as obtaining a copy of them.

Right of rectification: right to obtain the rectification of your inaccurate or erroneous data, aswell as to complete those that are incomplete.

Right of removal: right to request the elimination or deletion of your data and information undercertain circumstances. However, keep in mind that there are certain occasions in whichTelefónica S.A. is legally entitled to continue to keep and process your data (eg, for compliancewith a legal obligation to conserve data).

Right of limitation: right to restrict or limit the management of your data in certain circumstances(eg, if data deletion applies but, instead of eliminating them, you prefer that we block them andhandle them only for the purpose of their preservation since you will need them later to file aclaim). Again, keep in mind that there may be times when Telefónica S.A. is legally entitled toreject your limitation request.

Right of opposition: right to oppose Telefónica S.A. to manage your data for a specific purpose,in certain circumstances provided in the regulations and related to your personal situation. Insome cases we provide you with simple options to oppose you directly through the app (eg,opposition to receive commercial communications sent by Telefónica S.A.) and in other casesyou must contact us through email so that our Privacy team can evaluate your request in moredetail.

Right to data portability: right to receive your data in a commonly used format that allows you totransport them to another company, as well as, if applicable, to request Telefónica S.A. directtransmission to another company if it is technically possible. Remember that the right to dataportability is different from the right to portability of your phone number.

Right to not be the subject of automated decisions: the right to oppose being the subject of adecision based solely on the automated processing of data (without human intervention),including the preparation of profiles, which produces legal effects on you or affects you from ameaningful way.

Right to remove consent at any time: right to remove your consent at any time to themanagement of your data for a specific purpose, when based on legitimating basis.

You can check the full scope and detail of these rights on the website of the Spanish Data ProtectionAgency (SDPA).

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In general, you will be able to execute all these rights (at any time and for free) by writing to the privacyteam of Telefónica S.A. at privacidad@wayra.co

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For this, it is important to bear in mind that:

When you exercise a right, you must provide a copy of your official identity document (Example:DNI, NIE or Passport) and, if possible, send your request from the same email address that youused to register with Wayra.In the event that you decide to exercise one of these rights through a representative, it will benecessary to provide in the application, the documentation proving this condition (Example: in thecase of a voluntary representative, the power of representation in which shows the powers thatallow the exercise of such rights in your name).

The requests for the exercise of rights must be as specific and detailed as possible, indicating inthem the specific right that you wish to exercise.

However, you can exercise your right to oppose the receipt of commercial communications, by anychannel, from Telefónica S.A., just send us an email to privacidad@wayra.co

Lastly, remember that you also have the right to file a complaint with a Data Protection Control Authority(eg, the Spanish Data Protection Agency, whose contact information you can consult it here), especially ifyou estimate or understand that Telefónica S.A. has not correctly fulfilled the exercise of your dataprotection rights.

8. How do we use cookies and how can you manage them?

‍Summary: Telefónica S.A. uses own and third-party cookies to give you a more personalized service, to know howyou use the services and products of Wayra and, where appropriate, to show you advertising related toyour preferences and browsing habits. If you use Wayra, we understand that you accept its use.

Details: A cookie is a file that is downloaded to your device when accessing certain web pages and / orapplications. Cookies allow, among other things, store and retrieve information about your number ofvisits, browsing habits or the type of device and, depending on the information they contain and the wayyou use it, they can be used to recognize you as a user

Please note that in order to use Wayra it is necessary that you have cookies enabled, especially those of atechnical nature that are necessary for Telefónica S.A. to identify you as a registered user each time youaccess our website or application. Telefónica S.A uses the following types of cookies, which are treatedeither by us directly or by collaborating third parties:

Technical cookies: These are those used by Telefónica S.A that allow the user to navigate anduse the different options or services offered, such as controlling traffic and data communication,identifying the session, access restricted parts, remember the items that are in an order, performthe purchase process of an order, make the registration request, use security elements duringnavigation or store, disseminate and / or share content

Personalization Cookies: Those used by Telefónica S.A that allow the user to access Wayra withsome predefined general characteristics based on a series of criteria in their device, such aslanguage, the type of browser, the regional configuration from where you access, etc.

Analysis Cookies: These are those used by Telefónica S.A. and by third parties (GOOGLEANALYTICS, GOOGLE TAG MANAGER, GOOGLE FIREBASE, AKAMAI, COMSCORE,MIXPANEL, HOTJAR, HOCKEY APPS and HUBSPOT) that allow quantifying the number ofusers and thus perform the measurement and statistical analysis of the use and activity that users do, as well as develop navigation profiles to be able to introduce improvements in products andservices of Wayra.

Advertising and behavioral advertising cookies: These are those used by Telefónica S.A. and byour collaborators who manage the spaces that serve advertising of Telefónica S.A.(APPSFLYER, PUBMATIC, ADSRVR, RUBICON PROJECT, SMAATO, CONNEXITY , TURN,SIMPLIFI, AFFILINET, BING ADS, BLUEKAI, DOUBLECLICK, YOUTUBE, CRITEO,MOVISTAR, GOOGLE, YAHOO, FACEBOOK, TWITTER, ROCKETFUEL, MEDIAMATH,SMART, APPNEXUS, OPENX, ADGRAVITY, SMARTCLIP, ADFORM, HUBSPOT, CRAZY EGG,PLATFORM161 , ROCKET FUEL and / or THE TRADE DESK) that allow us to disseminateadequate and relevant advertising, measure the effectiveness of our online campaigns, as well asadapt the content of the ads to the navigation profile of each user on the Internet.

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Remember that you can allow, block or delete these cookies at any time through the configuration optionsof your device or terminal, as well as your internet browser. To do this, you can find the most up-to-datesupport information on these devices or browsers to know how you can eliminate cookies, since the way todo it can be different between different versions and operating systems. As an example:

In case you use any other Internet browser, we recommend that you look for the different cookiemanagement options that may be available, as well as, in general, any other tools available in the marketfor the blocking and / or administration of cookies (eg, Ghostery o Disconnect)

9. How do we protect your data?

‍Summary: Telefónica S.A. guarantees the security, secrecy and confidentiality of your data, communications andpersonal information adapted to the most demanding and robust security measures, and putting at yourdisposal tools and functionalities that allow you to control access to your Wayra account.

Details: Telefónica S.A. is Controler for ensuring the security, secrecy and confidentiality of your data,communications and personal information. Therefore, as part of our commitment and in compliance withcurrent legislation, we have adopted the most demanding and robust security measures and technicalmeans to prevent their loss, misuse or access without your authorization.

Also, we promise to act quickly and responsibly in the event that the security of your data may be indanger, and to inform you if necessary.

10. What do you have to keep in mind especially when using Wayra?

‍Summary: You Have to keep in mind certain aspects related to the minimum age of use of Wayra, the quality of thedata you provide us, as well as the removal of your user account.

Detail:

We recommend that you pay special attention to the following when registering and using Wayra::

Minimum age of use: in order to register and use Wayra you must be over 16 years old or havethe authorization of your parents and / or legal guardians. Therefore, by signing up for Wayra, youguarantee to Telefónica S.A. that you are older than that age or, otherwise, that you have theproper authorization. We can contact you at any time to verify if you meet this condition.

Quality of the data you provide: your personal data, mobile phone number and otherinformation that you provide us with in the registration and / or use of the services of Wayra mustalways be real, accurate and up-to-date. We provide you with the necessary tools and options tocontrol and update your personal information.

Removal of your user account: in general, there may be two situations in which the technicaldeactivation of your user account is carried out: 1) that you voluntarily request us to proceed tounsubscribe your user account in Wayra as explained in point 7 of this policy, and 2) that fromTelefónica S.A. proceed to the technical deactivation of your user account (eg, in cases in whichwe detect that you have breached the conditions of use of the service). In case of removal, youwill lose the information and data that you may have in [name P & S], as well as the right to useany benefits or services that you may have had at the time of removal and / or have previouslycontracted as a user of Wayra.